Subject: File No. 4-430
Date: 05/12/2000 2:47 PM
Peter W. Pfeiffer
1949 EUCLID AVE
SAN MARINO, CA 91108
Secratary, Securities and Exchange Commission
450 Fith Street, N.W.
Washington, D.C. 20549-0609
Dear Sir,
Responding to Item 1. I am a programmer analyst by profession and
I see no bar to implement dual pricing. As a private investor, I
would much prefer "penny" increments - a larger increment leads
to inefficient pricing, specialists and market makers picking up
greater spreads and profits.
Item 2. Computer file fields would have to be increased
slightly and access/display/submit screens would have to be
modified. These fields and screens, currently in much of the
industry, convert back and forth from fractions to decimals to
fractions.
Item 3. "customer confusion" would be decreased to a great
extent. Most investors can easily see a decimal change and its
implications such as percentage changes, versus the additional
steps in converting fractions to derivative numbers such as sums
and percentages of prices.
Quick now - What percent is 5/8 point to 8 3/16 ? hmm !
try 63 over 8.19 on your calculator. Easy 7.69%
(7.6923077 if neccessary).
Example 2 - What's the transaction cost for 100 shares at 8 3/16
per share plus fees of .015 % and commission of $45 ? hmmm !
Again so much easier in decimals and less chance for gross error.
Item 4. Dual pricing could be designed, tested, installed with
auto conversion, and in use by NASDAQ and the others within a
month. If NASDAQ wants to drag its feet, then market forces
would soon bring it into conformance. The question is - Why
complicate things with dual pricing ?
Items 5, 6, and 7 and conclusion. Decimal pricing should have
been implemented long ago. It's retention has only exacerbated
the the public distrust of the industry. Interim steps such as
the Pilot program and Dual Pricing will only serve to complicate
and confuse tradingissues, statements tax returns, all bookeeping
chores. Please initiate decimal pricing asap - July 3 !!! Then
the industry has the Fourth to fix any bugs. Please include
Monetary penalties for non-conformance.
Thank you for your attention.
Peter W. Pfeiffer